Key Findings

While the number of open U.S. investigations into foreign-bribery allegations dropped slightly in 2018, there was a notable increase in the number of open investigations worldwide, with an expanding range of investigating countries. Europe in particular saw its number of open investigations climb by approximately 37%, and the region now accounts for more than half of all foreign-bribery investigations.

The past year saw a notable growth in U.S. enforcement, with the number of U.S. enforcement actions increasing by more than half, approaching the record-setting volume of 2016. The pace of enforcement actions by non-U.S. authorities remained essentially steady.

There was also an increase in the number of investigations concerning bribery of domestic officials by foreign sources, showing a rise of approximately 15%. The total cumulative number of domestic enforcement actions also demonstrated a healthy growth of approximately 22%.

The Financial Services industry remained the most heavily investigated by United States agencies in connection with foreign-bribery allegations, accounting for approximately 17% of all such investigations. In other jurisdictions, however, the focus remained elsewhere—most prominently the Extractive Industries, Engineering/Construction, and Aerospace/Defense/ Security—with Financial Services accounting for only 6% of open investigations.